Art.33 Notification of a personal data breach to the supervisory authority
On becoming aware of a personal data breach, notify it to the competent supervisory authority without undue delay and, where feasible, not later than 72 hours after becoming aware, unless the breach is unlikely to result
5
artefacts
0
held by a system
2
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
none for this control
periodic reviewEvidence produced at each review
- The internal breach register covering all breaches including those assessed as not notifiable, with the risk assessment recorded for each · Policy repository / GRC workspace
- The methodology used to decide notifiability, and evidence it was applied rather than the decision reached first and documented after · Document repository
governing documentDocuments that govern the control
- The awareness timestamp per incident and the basis for it, since the 72 hours runs from awareness and not from confirmation or containment · HR system / LMS
- Notifications as submitted, checked against the four content elements Article 33(3) requires · Document repository
- Processor contract terms requiring notification without undue delay, and the notification times actually achieved · Vendor register / contract repository
First move
This control is evidenced by people and documents, not systems. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date. Do not try to automate it.
Common gaps auditors find
- The awareness clock started at the end of the investigation rather than at the point of reasonable certainty that a breach had occurred
- Breaches judged not notifiable with no documented assessment, leaving nothing for the authority to verify under Article 33(5)
- The register recording only breaches that were notified, so the unlikely to result in a risk decisions are invisible
- Processor notification terms that say promptly or within a commercially reasonable time, which cannot support the controller's 72 hours
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheetArt.32 Security of processing · Art.34 Communication of a personal data breach to the data subject